Form 990 Schedule M: Reporting, Valuing, and Filing Noncash Gifts

A tax-exempt organization must file Form 990 Schedule M when it received more than $25,000 in noncash contributions during the year, or when it received any contribution of art, historical treasures, or a qualified conservation contribution regardless of amount. The schedule sorts those donations by property type, reports the revenue for each, and explains how the values were determined.

When Schedule M Is Required

Two questions on Form 990, Part IV send you to Schedule M. Line 29 asks whether the organization received more than $25,000 in total noncash contributions. Line 30 asks whether it received art, historical treasures, or a qualified conservation contribution. A “Yes” to either triggers the filing.¹

The $25,000 threshold is measured against the aggregate on Form 990, Part VIII, line 1g, which captures all noncash contributions recognized as revenue for the year. A stream of small in-kind gifts can add up past the line without any single donation looking large, so a running total kept through the year prevents surprises at filing.²

What Counts as a Noncash Contribution

A noncash contribution is any donation of property, goods, or assets other than cash or a cash equivalent such as a check or wire transfer. Publicly traded stock, real estate, vehicles, clothing, medical supplies, food inventory, and intellectual property are all common examples.

Donated services do not belong on Schedule M. Pro bono legal work, volunteer labor, and similar contributions of time are not reported as revenue on Form 990, Part VIII, and they don’t flow into the noncash totals. The organization can describe their impact in Part III of Form 990 (Statement of Program Service Accomplishments), but nowhere on Schedule M.³

Digital Assets and Cryptocurrency

Cryptocurrency, NFTs, stablecoins, and other digital assets are treated as property for federal tax purposes, not currency. A Bitcoin gift is a noncash contribution reported on Schedule M like any other donated property. If the claimed value exceeds $5,000, the organization must be prepared to sign the donor’s Form 8283, and if it converts the digital asset to cash within three years, it must file Form 8282.⁴

Securities

Schedule M splits securities into four separate lines, and each gift belongs on exactly one:

Line 9, publicly traded securities: stocks, bonds, and mutual fund shares listed on an exchange or traded over the counter.
Line 10, closely held stock: shares in a corporation that are not publicly traded.
Line 11, partnership, LLC, or trust interests: ownership stakes in pass-through entities or trusts.
Line 12, miscellaneous securities: anything that doesn’t fit the first three.

When you count items in column (b), each separate gift of securities is one item, not one per share. A donor who transfers 500 shares of one stock in a single gift counts as one contribution.²

How to Value What You Received

Every noncash contribution starts with fair market value on the date of the donation. FMV is the price the property would fetch between a willing buyer and a willing seller, with neither under pressure and both reasonably informed. Different property types get there different ways.

Publicly Traded Securities

FMV equals the average of the highest and lowest quoted selling prices on the date of the contribution. A stock that traded between a high of $50 and a low of $46 that day has an FMV of $48. No appraisal needed, because the market supplies a transparent price.⁵

Property Requiring a Qualified Appraisal

For donated property other than publicly traded securities where the donor claims a deduction of more than $5,000, the donor must obtain a qualified appraisal.⁶ The receiving organization doesn’t commission or pay for the appraisal. It sees the results when the donor brings Form 8283 for signature, and the appraised value is what flows into Schedule M column (c).⁷

Inventory

Donated inventory still goes on Schedule M at FMV in column (c), with the valuation method described in column (d). The donor’s deduction may be limited to the lesser of FMV or cost basis, but that limitation is a donor issue and doesn’t change what the organization reports.⁸

Vehicles, Boats, and Airplanes

When your organization receives a donated vehicle, boat, or airplane with a claimed value above $500, you must furnish the donor a contemporaneous written acknowledgment on Form 1098-C within 30 days of the sale or of the contribution date, depending on how the vehicle is used. If the organization sells the vehicle rather than using it, the donor’s deduction is generally limited to the gross sale proceeds.⁹

Documents to Have in Hand Before Filing

Schedule M is the last step in a chain that begins at the moment each gift arrives. Gaps in that chain make the schedule hard to complete accurately.

Written Acknowledgments

For any single noncash contribution valued at $250 or more, provide the donor a contemporaneous written acknowledgment. It must include the organization’s name, a description (but not the value) of the property, and a statement about whether the organization provided any goods or services in exchange. If it did, include a description and a good-faith estimate of their value.¹⁰

Form 8283

Donors claiming deductions for noncash property over $5,000 (other than publicly traded securities) must complete Section B of Form 8283. The organization signs Part V, “Donee Acknowledgment,” to confirm receipt of the property described. Signing does not mean the organization agrees with the value.¹¹

Signing also commits the organization to filing Form 8282 if it sells, exchanges, or otherwise disposes of the property within three years. Keep a copy of every Form 8283 signed during the year. The total number is reported on Line 29 of Schedule M, Part I.²

An Internal Summary

Before opening the schedule itself, compile a worksheet listing, by property category, the type of property, the date of each contribution, the FMV, and the valuation method used (qualified appraisal, market quotation, cost, sale of comparable properties, replacement cost, or expert opinion). Part I is organized around those same categories, so the transfer becomes mechanical.

Filling Out Part I

Part I is a grid with 28 lines covering named property types (art, securities, real estate, food inventory, and so on) plus four “Other” lines for anything unnamed. Each line has four columns.

Column (a), Check if applicable: check every property type received during the year.
Column (b), Number of contributions or items: enter either the count of separate contributions or the count of individual items. Whichever method you use, explain it in Part II. For securities, each gift is one item regardless of share count.
Column (c), Noncash contribution amounts: enter the revenue reported on Form 990, Part VIII, line 1g for that property type. If you checked column (a) but recognized no revenue, enter zero and explain in Part II.²
Column (d), Method of determining revenues: describe how you reached the column (c) figure. Acceptable descriptions include cost, selling price of donated property, sale of comparable properties, replacement cost, or opinions of experts.⁵

Column (c) has to tie exactly to Part VIII, line 1g. A mismatch between the two figures is the most common reason the IRS follows up, so reconcile those numbers before you sign off.

Filling Out Part II

Part II is a free-text area for supplemental information, and several disclosures there are mandatory:

The column (b) counting method used for each property type where column (a) is checked, and whether the count reflects contributions, individual items, or both.
If the organization answered “Yes” to line 30a (holding donated property for at least three years without being required to use it for exempt purposes throughout that period), describe the arrangement.
If the organization uses third parties or related organizations to solicit, process, or sell noncash contributions, describe those arrangements (line 32b).²
If column (a) is checked for a property type but no amount is shown in column (c), explain why (line 33). This often happens when property was received but revenue hasn’t been recognized yet.

Part II is the place to head off auditor questions. Restrictions on an in-kind gift, a partial interest, or a year-end donation still being valued all deserve a sentence here.

After Filing: Form 8282 and Form 8899

Schedule M isn’t the end of the organization’s reporting obligations. If it sells, exchanges, or otherwise disposes of donated property within three years of receipt, it must file Form 8282 with the IRS and send a copy to the original donor. This applies to any property for which the organization signed a Form 8283.¹²

Form 8282 is due within 125 days after the date of disposition. Two exceptions: property valued at $500 or less, and property consumed or distributed for charitable purposes rather than sold. Organizations that receive cryptocurrency and convert it to cash shortly after the donation trigger the Form 8282 filing, because the conversion is a disposition inside the three-year window.⁴

Donated intellectual property, such as patents, copyrights, trademarks, trade secrets, or software, brings an ongoing obligation. If it produces net income, the organization files Form 8899 for each tax year the property generates income, for up to 10 years from the contribution date or until the property’s legal life expires, whichever comes first. Form 8899 is due by the last day of the first full month after the organization’s tax year ends, with a copy to the donor. Missing it can trigger penalties under sections 6721 through 6724 of the Internal Revenue Code.¹³

Deadlines and Penalties

Schedule M is filed with Form 990, so it follows the Form 990 due date: the 15th day of the 5th month after the fiscal year ends. Calendar-year organizations file by May 15, with a six-month extension available to November 15.¹⁴

An incomplete Schedule M counts as an incomplete Form 990. Late or incomplete returns run $20 per day, with a maximum for smaller organizations of the lesser of $10,500 or 5% of gross receipts for the year. Organizations with gross receipts above roughly $1.1 million face steeper daily amounts. If the IRS sets a specific correction deadline and a responsible individual fails to comply, that individual can be personally charged $10 per day up to $5,000.¹⁵

Those daily amounts compound faster than most organizations expect, and the personal exposure for responsible individuals is what tends to catch people off guard. Building Schedule M preparation into the year-end close, rather than treating it as a last-minute attachment, is the simplest way to keep it clean.

1
Internal Revenue Service. Return of Organization Exempt From Income Tax
2
Internal Revenue Service. Schedule M (Form 990) – Noncash Contributions
3
Internal Revenue Service. Exempt Organizations Annual Reporting Requirements – Form 990 Part VIII-IX and Schedule D
4
Internal Revenue Service. Frequently Asked Questions on Virtual Currency Transactions
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Internal Revenue Service. Publication 561 – Determining the Value of Donated Property
6
Office of the Law Revision Counsel. 26 USC 170 – Charitable, Etc., Contributions and Gifts
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Internal Revenue Service. Instructions for Form 8283
8
Internal Revenue Service. Publication 526 – Charitable Contributions
9
Internal Revenue Service. Instructions for Form 1098-C
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Internal Revenue Service. Charitable Contributions – Written Acknowledgments
11
Internal Revenue Service. Form 8283 – Noncash Charitable Contributions
12
Internal Revenue Service. Charitable Organizations – Substantiating Noncash Contributions
13
Internal Revenue Service. Form 8899 – Notice of Income From Donated Intellectual Property
14
Internal Revenue Service. Return Due Dates for Exempt Organizations – Annual Return
15
Internal Revenue Service. Annual Exempt Organization Return – Penalties for Failure to File